## Facts

- In October 1984, fifteen-year-old R.R. left his parents’ home and lived with various relatives.
- The parents, C.R. and R.R., claimed R.R. left voluntarily after they demanded he abandon his homosexual way of life.
- On R.R.’s behalf, it was alleged that he was forced out of the parents’ home.
- In July 1985, R.R. was adjudicated dependent on the State of Utah without objection by his parents.
- The Utah Department of Family Services (DFS) took temporary custody of R.R.
- The State paid for R.R.’s support during the period in which DFS had temporary custody.
- The temporary custody order expired in October 1986, and custody of R.R. was returned to the parents under DFS supervision.
- The State later sought reimbursement of $1,159.06 for amounts spent on R.R. between January 1985 and October 1986.
- The parents opposed reimbursement, arguing that R.R. became emancipated when he left home in October 1984, ending their duty to support him.
- The State responded that the parents had not shown emancipation because they presented no evidence that R.R. could live independently or support himself.
- The juvenile court declined to apply the doctrine of emancipation and ordered the parents to reimburse the State; the parents appealed.

## Issues

1. Whether the parents could avoid reimbursing the State for support of their minor child by claiming the child was emancipated when he left home.
2. Whether a minor’s departure from the parental home—amid family conflict and without proof of self-support—establishes emancipation sufficient to end the parents’ support obligation.

## Decision

- The court upheld the reimbursement order against the parents.
- The court rejected the parents’ emancipation defense on these facts.
- The parents were required to reimburse the State $1,159.06 for support provided to R.R. during the claimed period.

## Legal Principles

- Parents have a legal duty to support their minor children, and the State may seek repayment from those legally responsible when the State provides support due to a dependency adjudication.
- Emancipation is not established merely because a minor leaves the parental home or because the parents and child are in conflict.
- A party asserting emancipation bears the burden to show facts that amount to emancipation, including that the minor can function independently in a practical, financial sense.
- Moral disapproval of a child’s lifestyle does not, by itself, end the parents’ duty of support or shift the costs of care to the State.
- When the record lacks evidence that the child is self-supporting or able to provide his own residence, a court may decline to treat the child as emancipated for purposes of parental support and reimbursement.

## Conclusion

The court affirmed an order requiring C.R. and R.R. to reimburse the State of Utah for support paid on behalf of their minor son after he was adjudicated dependent, holding that the parents’ claim of emancipation based on the child’s departure from home and family conflict—without proof of independent self-support—did not end their support duty.


State v. C.R. and R.R., 797 P.2d 459 (1990)